プライバシーポリシー

Clicking Media Limited ( UK )  (“the Company” or “Clicking Media” or “we“) is the owner of the website brokertrending.com (“the Website“).  Clicking Media is committed to protecting your privacy and we understand you want to keep your information private, safe and discrete. This Privacy Policy is designed to help you decide whether to use the Service and in what manner, and it describes how we collect, store and use information on individuals who use the Service.

By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.

Table of Contents

1. Definitions used in this Policy
2. Data protection principles we follow
3. What rights do you have regarding your Personal Data
4. What Personal Data we gather about you
5. How we use your Personal Data
6. Who else has access to your Personal Data
7. How we secure your data
8. Information about cookies
9. Contact information

Definitions

Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – Clicking Media

Data Protection Principles

We promise to follow the following data protection principles:

• Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
• Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
• Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
• Processing is limited with a time period. We will not store your personal data for longer than needed.
• We will do our best to ensure the accuracy of data.
• We will do our best to ensure the integrity and confidentiality of data.

Data Subject’s rights

The Data Subject has the following rights:

1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

To access or delete data held on you, please visit our プライバシーツール page.

Data we gather

Information you have provided us with
This might be your e-mail address, name and password – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.

 Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example,  your IP address, etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.

 Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.

Publicly available information
We might gather information about you that is publicly available.

How we use your Personal Data

We use your Personal Data in order to:

• provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
• enhance your customer experience;
• fulfil an obligation under law or contract.

We use your Personal Data on legitimate grounds and/or with your Consent.

On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:

• to identify you;
• to provide you a service or to send/offer you a product;
• to communicate either for sales or invoicing;

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

• to send you personalized offers* (from us and/or our carefully selected partners);
• to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
• to conduct questionnaires concerning client satisfaction;

As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.

With your consent we Process your Personal Data for the following purposes:

• to send you newsletters and campaign offers (from us and/or our carefully selected partners);
• for other purposes we have asked your consent for;

We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:

• the link between purposes, context and nature of Personal Data is suitable for further Processing;
• the further Processing would not harm your interests and
• there would be appropriate safeguard for Processing.

We will inform you of any further Processing and purposes.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will do our best and take all reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy.

Who else can access your Personal Data

We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:

Our processing partners:

• Siteground Spain SL (Hosting &  Webserver backups)  www.siteground.com/privacy.htm
• WordPress.org (US)  (CMS)
• Cloudflare Inc ( US ) (CDN services) , https://www.cloudflare.com/privacypolicy/
• Timersys WP LLC ( US ) (GeoTargeting services) https://geotargetingwp.com/privacy-policy

Connected third parties:

• Google Analytics by Google ( US )  https://policies.google.com/privacy
• Bemob ( Czech Republic )  (Tracking software ) which privacy policy can be found at: https://bemob.com/privacy-policy

We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Links to third party Websites

We offer affiliate links and links for your use and reference on our site. We are in no way responsible for the content on these websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and are not affiliated with us. It is your responsibility to check these policies and terms of use for information before you submit any personal data to these websites.

How we secure your data

We do our best to keep your Personal Data safe.  We use safe protocols for communication and transferring data (such as HTTPS).

We monitor our systems for possible vulnerabilities and attacks via the following platforms:

1. WP security plugin , Protects our site from unauthorized access and attacks, including the blocking of malicious URLs, requests and comment spam, two-factor authentication for user access, protection from brute force attacks and firewall.
2. Let’s Encrypt SSL certificate
3. Cloudflare, DDoS Protection

You may complete a registration process when you sign up to use parts of the websites. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone.

Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.

Whenever you create a password, then to protect your account you should choose a strong password, meaning it should be lengthy and include a mixture of letters and numbers with mix of CAPS.

We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us.

Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:

1. Use of secure servers;
2. Use of firewalls;
3. Use of encryption;
4. Physical access controls at data centres;
5. Information access controls;
6. Use of back-up systems;

Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret.

Cookies and other technologies we use

You can find here our cookies policy.

Children

We do not intend to collect or knowingly collect information from children. We do not target children with our services.

Contact Information

Clicking Media Ltd

Kemp House 152 City Road

London  EC1V 2NK

Email: info@clickingmedia.co.uk

Phone: +44 2036952374

Contact Information

Supervisory Authority
Website: https://ico.org.uk
Email: international.team@ico.org.uk
Phone: 0303 123 1113

Changes to this Privacy Policy

We reserve the right to make change to this Privacy Policy.
Last modification was made March 29, 2020.